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Privacy Policy

CEG UNW Online Ltd is a recognised affiliate college of the University of Central Lancashire run in partnership with CEG Digital Ltd to deliver a selection of its online programmes.

CEG Digital Limited is a subsidiary of Cambridge Education Group Ltd. CEG UNW Online Ltd respects your privacy and is committed to protecting your personal data.

Key sections of this Privacy Notice are:

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA

5. HOW WE USE YOUR PERSONAL DATA

6. DISCLOSURES OF YOUR PERSONAL DATA

7. INTERNATIONAL TRANSFERS

8. DATA SECURITY

9. DATA RETENTION

10. YOUR LEGAL RIGHTS

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username, student ID number, marital status, title, date of birth, gender, photograph, immigration status, right to work, curriculum vitae (CV), covering letter, academic record, employment history and references.

  • Special Category Data includes details about your race or ethnicity, religious beliefs, information about your health, genetic and biometric data (we have in place safeguards for processing such data including confidentiality agreements and restrictions on access to such data).

  • Criminal Conviction Data includes details about any unspent criminal convictions and offences (where not covered by Section 1 (1) of the Rehabilitation of Offenders Act 1974) (we have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data).

  • Contact Data includes your home address, email address and telephone numbers

  • Financial Data includes payment reference and identification details

  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use when accessing our CEG UNW Online Ltd or any of the websites of our subsidiaries accessed from that website.

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our websites and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Aggregated Data includes statistical or demographic data which we may collect, use and share for any purpose. Where Aggregated Data can directly or indirectly identify you, we will use it in accordance with this Privacy Notice.

2.1. If you do not provide us with personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with education services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

4. OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where it is necessary for us to perform a contract entered into with you or is necessary for us to take steps (at your request) prior to us entering into a contract (CONTRACT).

  • Where we have a legitimate organisational interest and use your personal data in a way that you would reasonably expect, and which has a minimal impact on your privacy (LEGITIMATE INTERESTS).

  • Where we need to comply with a legal or regulatory obligation (LEGAL OBLIGATION).

  • Where you have given us your consent to process your personal data (CONSENT).

  • Where there is an emergency situation, for example, if you needed emergency medical treatment (VITAL INTERESTS).

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the processing of Special Category Data or when sending direct marketing communications to you via email or text message. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

You have the right to withdraw your consent at any time by contacting us.

Please see Section 10: Your legal rights

5. HOW WE USE YOUR PERSONAL DATA

5.1. Prospective Students and Agents

Purpose/Activity

Type of Data

Lawful basis for proceeding

To register you on our website and subscribe to our services

Identity

Contact

Marketing and Communications

Data

Contract

Consent

To correspond with you

Identity

Contact

Contract

 

Provision of data to third parties

   

To educational agents where the agent has submitted an application on behalf of a prospective student

Identity

Contact

Financial 

Criminal Conviction

Special category

Contract

Consent

To third party online conversion service where an applicant has started the application process but does not complete it

Identity

Contact

Legitimate interest (CEG UNW Online Ltd has a business interest in securing applications for its courses)

 

To UK Visas and Immigration (UKVI) to facilitate the application for an employment visa

Identity

Contact

Legal obligation

 

To Immigration and Naturalisation Service (Netherlands)

Identity

Contact

Legal obligation

 

To cloud hosted virtual learning environment (VLE) services (e.g. Moodle and Canvas)

Identity

Contact

Legitimate interest (CEG UNW Online Ltd has a business requirement to use VLEs in order to provide online teaching resources)

 

5.2 Enrolled Students

Purpose/Activity

Type of Data

Lawful basis for processing

To register you for our services as an enrolled student

Identity

Contact

Financial

Transaction

Special Category

Contract

Consent

To provide you with ongoing services after enrolment including:

(i)provision of core teaching and learning services

(ii) administration including maintaining student records, processing fees, managing accommodation

(iii) providing services including library, IT and information services and other student support services (excluding welfare and medical)

Identity

Contact

Financial

Contract

To provide you with ongoing services after enrolment in respect of student welfare

Identity

Special Category

Contract 

Consent

To provide you with reports on your progress

Identity

Contact

Contract

To process student complaints and grievances

Identity

Contact

Special Category

Legitimate interests (it is in the interest of both parties for CEG UNW Online Ltd to investigate and attempt to resolve complaints and grievances)

Consent

To carry out internal research and statistical analysis

Identity

Legitimate interests (to monitor and evaluate the performance and effectiveness of our courses)

To conduct lesson observations using sound and video recording software

Identity

Legitimate interests (it is appropriate for CEG UNW Online Ltd to monitor teaching quality and to share examples of good practice as an internal training resource).

To take photographs and videos of students for marketing purposes (including for use in brochures, on our website and in promotional videos)

Identity

Consent

To use examples of students' work in class for the improvement of teaching and learning practice.

Identity

Legitimate interests (it is appropriate for CEG UNW Online Ltd to share examples of good practice during lessons. Some items may be named.)

Provision of personal data to third parties

   

Internal

   

To enable CEG UNW Online Ltd companies to provide (i) application and admissions services (ii) core teaching and learning services, (iii) student administration services and (iv) student welfare services

Special Category

Consent

External

   

To financial or government sponsors of a course

Identity

Contact

Special Category

Legal Obligation

Consent

CEG Digital university partners

Identity

Contact

Financial

Transaction

Special Category

Legitimate interests. (Our business model for operating Online learning programmes requires partnership with universities. CEG UNW Online Ltd has a data sharing agreement with each partner university.)

Consent

To HM Revenue & Customs for reporting of financial processing activities

Identity

Contact

Financial

Transaction

Legal obligation

To service providers worldwide who provide IT and system administration services

Identity

Contact

Legitimate interests (CEG UNW Online Ltd has a business requirement to use third party providers for specialist services)

To cloud hosted virtual learning environment (VLE) services (e.g. Moodle & Canvas)

Identity

Contact

Legitimate interests (CEG UNW Online Ltd has a business requirement to use VLEs in order to provide online teaching resources)

To deliver and record lessons, lecturers or webinars online using cloud-hosted sound and video (e.g. Skype, Microsoft Teams)

Identity

Contact

Contract

Legitimate interests (CEG UNW Online Ltd has a business requirement to use these services to provide online teaching and accessible lesson resources for students learning remotely and needing to access recordings of lessons.)

Professional advisors subject to a duty confidentiality (e.g. lawyers, bankers, insurers, auditors)

Identity

Contact

Financial

Transaction

Special Category

Legitimate interests (CEG UNW Online Ltd has a business requirement to seek specialist professional advice that cannot be provided internally)

Consent

To the Police regarding a safeguarding concern or in connection with the prevention of reporting of a crime.

 

Identity

Contact

Special Category

Legal obligation or Vital interests (depending on the circumstances)

Legal obligation or Vital interests (depending on the circumstances)

5.3 Employment Candidates

Purpose/Activity

Type of Data

Lawful basis for processing

To assess your skills, qualifications and suitability for the role

Identity

Contact

Contract

To assess information about disability status to consider whether we need to make appropriate adjustments during the recruitment process

Special Category

Consent

Once an offer has been made to carry out background and reference checks, where applicable (excluding criminal record)

Identity

Contact

Contract

Once an offer has been made to carry out a criminal record check where required by law due to the nature of the role applied for

Identity

Criminal Conviction

Contract

Legal obligation

To communicate with you about the recruitment process

Contact

Contract

To comply with equal opportunities monitoring and reporting requirements

Identity

Special Category

Legal obligations

Legal obligation and necessary for statistical purposes

5.4 All visitors to website

Purpose/Activity

Type of Data

Lawful basis for processing

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Identity

Contact

Profile

Usage

Technical

Marketing and Communications

Legitimate interests (to study how our services are used, to develop them, to grow our business and to inform our marketing strategy)

Consent

To use data analytics to improve our website, services, marketing, customer relationships and experiences

Technical 

Usage

Legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

Identity

Contact

Technical

Usage

Profile

Legitimate interests (to develop our services and grow our business)

Provision of personal data to third parties

   

External

   

To service providers worldwide acting as processors who provide Finance, IT and system administration services

Identity

Contact

Technical

Usage

Profile

Legitimate interests (CEG UNW Online Ltd have a business requirement to use specialist Finance, IT and system administration providers that cannot be provided internally)

To third parties to whom we ma choose to sell, transfer or merge parts of our business as our assets.

Identity

Contact

Legitimate interests (CEG UNW Online Ltd may wish to do this as part of its business strategy)

5.5. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

5.6. Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside CEG UNW Online Ltd for marketing purposes.

5.7. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing a service or other transaction.

5.8. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

7. INTERNATIONAL TRANSFERS

We share your personal data within Cambridge Education Group. This will involve in some cases transferring your data outside the European Economic Area (EEA) and the UK.

Some of our external third parties are based outside the EEA and the UK so their processing of your personal data will involve a transfer of data outside the EEA and the UK.

Whenever we transfer your personal data out of the EEA and the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (as at the date of this Privacy Notice this applies to Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay).

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if we have specific contracts approved by the European Commission in place which give personal data the same protection it has in Europe and the UK, with standard contractual clauses. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.

8. DATA SECURITY

The personal data that we collect from you will be stored by cloud providers or third-party services hosted in the Microsoft Azure UK or Western Europe regions. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

9.1. How long will you use my personal data for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Details of retention periods for different aspects of your personal data are set out in the table below:

Type of data

Retention timescale

STUDENT RECORDS

 

1. Student Recruitment

 

Enquiries from prospective students (CEG UNW Online Ltd Digital)

Where we hold your personal information for marketing purposes, we will retain that information for a period of three years (or longer if you agree)

Records of campaigns and events (CEG UNW Online Ltd Digital)

1 year from last sales activity

2. Applications - Not Progressed (Closed)

 

Application form

2 Years after date of closure

Offer of place and related correspondence

2 Years after date of closure

Acceptance of place and related correspondence

N/A

3.a. Applications - Registered Paid

 

Application form

2 Years after date of Withdrawal

Offer of place and related correspondence

2 Years after date of Withdrawal

Acceptance of place and related correspondence

2 Years after date of Withdrawal

Centre-related Application and Registration Forms

2 Years after date of Withdrawal

Copies of invoices

7 Years after date of Withdrawal

4. Enrolled Students - Withdrawn

 

Application form (incl scholarship applications)

Original course end date + 3 years

Offer of place and related correspondence

Original course end date + 3 years

Acceptance of place and related correspondence

Original course end date + 3 years

Details of criminal convictions

Original course end date + 3 years

Passport Documentation/Previous Visas

Original course end date + 3 years

Academic and English Documents; Reports

Original course end date + 3 years

Offer/offer pack Forms

Original course end date + 3 years

Copies of invoices

7 Years after date of Withdrawal

5. Arrived/Enrolled Students - Completed

 

Application form

Completion of course + 3 years

Offer of place and related correspondence

Completion of course + 3 years

Acceptance of place and related correspondence

Completion of course + 3 years

Academic and English Documents; Reports

Completion of course + 3 years

Copies of invoices

7 years after date of Withdrawal

Basic student record comprising student name, enrolment date, end date, institution

Permanently

Copies of filmed lesson observations

Completion of academic year + 1 term

CANDIDATE RECORDS

 

Application forms, CVs and interview notes (unsuccessful candidates)

Last communication to candidate + 6 months

Application forms, CVs and interview notes (successful candidates)

Part of personnel files. 6 years after employment ceases.

In some circumstances you can ask us to delete your data: see Request erasure in Section 10 Your legal rights for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you

10. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data - (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of your personal data - This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data – (commonly known as the “right to be forgotten”). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data - where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request transfer of your personal data – (also known as the “right to data portability”) We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Right to withdraw consent – However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

10.1. Data Protection Officer

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer, Lisa Tyler in writing with full details of your request. You can send an email to DPO@ceg-uk.com or can write to us at:

Lisa Tyler

Data Protection Officer

Cambridge Education Group Limited, 51-53 Hills Road, Cambridge, CB2 1NT

10.2. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

10.3. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10.4. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.5. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Last updated 21/04/21.